Chichester Local Plan 2021 - 2039: Proposed Submission

We welcome the focus in the policy wording and supporting text on the Sub Regional Centres, Settlement Hubs and Service Villages as the main locations for strategic site allocations, employment, retail, social and community facilities.

We support the Settlement Hub classification for Southbourne as the District’s third largest settlement (in population size) after Chichester and Selsey and joint fourth highest ranking settlement in terms of number of key services and facilities.

With good access to the regional road network and public transport links Southbourne has a key role to play in meeting the District’s full local housing need.

The draft policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The draft policy is not consistent with the strategic objective of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text. Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF). Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance. Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities. A number of smaller sites can collectively bring the benefits of a single major large-scale development, with the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly. The ‘Land at Cooks Lane’ is identified in consecutive versions of the Chichester SHLAAs and HELAAs as ‘available’, ‘achievable’ and ‘suitable’ during years 0-5 of the Plan period. The site is located outside of the AONB and could collectively contribute to Community, Blue and Green Infrastructure and recreation opportunities, such as the ‘Green Ring’ initiative being carried forward through the Neighbourhood Plan process. It also has the added benefit from proximity to Southbourne Railway Station providing connections to Chichester, Portsmouth/Southampton and the wider region and formal support from Network Rail in relation to the Southbourne level-crossing. In order to meet the housing needs of Southbourne over the Plan period and provide sufficient flexibility to achieve early delivery, should other sites and / or allocations be delayed, the policy wording would also allow development to be dispersed around the settlement to allow the phasing of well-integrated high quality sustainable urban extensions providing good access to facilities and sustainable forms of transport. Through the implementation of the IDP all development proposals would be required make proportionate contributions towards the delivery of the necessary infrastructure in a timely manner. The current wording and approach to the BLD would not achieve this. With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text.

Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance.

Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities. A number of smaller sites can collectively bring the benefits of a single major large-scale development, with the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly.

The ‘Land at Cooks Lane’ is identified in consecutive versions of the Chichester SHLAAs and HELAAs as ‘available’, ‘achievable’ and ‘suitable’ during years 0-5 of the Plan period. The site is located outside of the AONB and could collectively contribute to Community, Blue and Green Infrastructure and recreation opportunities, such as the ‘Green Ring’ initiative being carried forward through the Neighbourhood Plan process. It also has the added benefit from proximity to Southbourne Railway Station providing connections to Chichester, Portsmouth/Southampton and the wider region and formal support from Network Rail in relation to the Southbourne level-crossing.

In order to meet the housing needs of Southbourne over the Plan period and provide sufficient flexibility to achieve early delivery, should other sites and / or allocations be delayed, the policy wording would also allow development to be dispersed around the settlement to allow the phasing of well-integrated high quality sustainable urban extensions providing good access to facilities and sustainable forms of transport. Through the implementation of the IDP all development proposals would be required make proportionate contributions towards the delivery of the necessary infrastructure in a timely manner. The current wording and approach to the BLD would not achieve this.

With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

We therefore request the Council review the approach towards meeting the full local housing needs of the District and plan for an increased supply of housing over the Plan period, in particular within the early years of the Plan.

The District’s local housing need and the development strategy is ‘unsound’. The policy requirement to deliver 10,359 dwellings / 575 dwellings per annum, (dpa) over the Plan period (2021-2039), is derived from a suppressed objectively assessed need of 11,497 / 638 dpa. Whereas this is referred to in paragraph 5.2 of the supporting text as a result of constrained highway capacity on the A27 there is provision within draft Policy I1 of the Proposed Submission Local Plan and the associated Infrastructure Delivery Plan (IDP) to ensure the infrastructure requirements and funding mechanisms are available to support the delivery of housing.